IR 05000302/2013008
| ML13311A037 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/06/2013 |
| From: | Marc Ferdas Decommissioning Branch I |
| To: | Hobbs T Duke Energy Florida |
| References | |
| IR-13-008 | |
| Download: ML13311A037 (13) | |
Text
UNITED STATES ber 6, 2013
SUBJECT:
NRC INSPECTION REPORT NO. 05000302/2013008, DUKE ENERGY FLORIDA, INC., CRYSTAL RIVER NUCLEAR PLANT, CRYSTAL RIVER, FLORIDA
Dear Mr. Hobbs:
On September 30 - October 3, 2013, the U.S. Nuclear Regulatory Commission (NRC)
conducted an inspection at Crystal River Unit 3 (CR-3). The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with Mike Delowery, Decommissioning Planning Manager, and other members of your staff at the conclusion of the inspection; and are described in the enclosed report. No findings of safety significance were identified.
Current NRC regulations and guidance are included on the NRC's website at~~~=.=."""'
select Nuclear Materials; Med, lnd, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at
~~~=.)!.' select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00a.m. to 5:30p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Steve Hammann, at 610-337-5399, if you have any questions regarding this matter.
/ltly,) M-Marc S. Ferdas, Chief Decommissioning Branch Division of Nuclear Materials Safety Enclosure:
Inspection Report No. 05000302/2013008 cc w/Enclosure:
via Listserv
EXECUTIVE SUMMARY
Duke Energy
Crystal River Nuclear Plant NRC Inspection Report No. 05000302/2013008 An announced safety inspection was conducted from September 30- October 3, 2013 at CR-3.
The inspection included a review of operations and management oversight, maintenance, corrective action program (CAP) implementation, fire protection, and plant support activities.
The inspection consisted of observations by the inspectors, interviews with Duke Energy personnel, a review of procedures and records, and plant walkdowns. The U.S. Nuclear Regulatory Commission's (NRC's) program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561,
"Decommissioning Power Reactor Inspection Program." Based on the results of this inspection, no findings of safety significance were identified.
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REPORT DETAILS
1.0 Background CR-3 shut down on September 26, 2009 for a planned steam generator replacement outage. Completion of outage activities and restart of the plant were delayed due to internal cracking in one containment bay wall. In 2011, after repairing the initial damage and while returning the containment structure to service, additional cracking occurred in other sections of the containment concrete wall. Fuel was removed from the reactor and placed in the spent fuel pool on May 28, 2011. On February 20, 2013, Duke Energy sent a letter (ML13056A005) to the NRC certifying the permanent cessation of activities and certifying that the fuel had been permanently removed from reactor. This met the requirements of 10 Code of Federal Regulations (CFR) 50.82(a)(1 )(i) and 50.82(a)(1 )(ii).
CR-3 is currently in the "Post Operation Transitional Phase" of decommissioning as described in IMC 2561.
2.0 Post Operation Transition Phase Performance and Status Review
a. Inspection Scope
(Inspection Procedures (IPs) 36801, 37801, 40801, 62801, 64704, 71801,83750,84750,86750, 71111.11)
An announced safety inspection was conducted from September 30-October 3, 2013 at CR-3. The inspection consisted of observations by the inspectors, interviews with Duke Energy personnel, review of procedures and records, and plant walkdowns.
The inspectors assessed management oversight of the site's transition to decommissioning status and reviewed organization, staffing levels, and personnel qualifications to ensure safe storage of radioactive materials are not adversely impacted.
Inspectors evaluated employee training, including that of contracted work force.
Inspectors reviewed Duke Energy's process for reviewing, responding to, and implementing regulatory information and the methods in which Duke Energy resolved employee/safety concerns and provided information to employees. The inspectors toured the control room and verified that requirements detailed in plant technical specifications (TS) were being met. The inspectors also reviewed the CAP to determine if issues were being properly identified, evaluated, and prioritized, and corrective actions were being appropriately implemented.
The inspectors reviewed the proposed modifications to stabilize the containment building and reviewed several related Engineering Changes (ECs). The inspectors also verified that the ECs were performed in accordance with site procedures and 50.59 screenings had been completed. The inspectors assessed the details of the containment stabilization safety evaluations to verify that Duke Energy's proposed activities did not involve an unreviewed safety question or changes toTS.
The inspectors reviewed the programs for the safe wet storage of spent fuel and verified that maintenance was being performed within the established frequencies and that the Inspection Report No. 05000302/2013008 G:\WordDocs\Current\lnsp Letter\LDPR-72.2013008.doc
equipment was being properly maintained. The inspectors also reviewed the material condition of systems used to support spent fuel pool cooling during plant tours.
The inspectors reviewed activities and documentation associated with the occupational exposure, radioactive effluent control, and site radiological environmental monitoring program (REMP) to determine the effectiveness of site radiological programs. The inspectors reviewed radioactive gaseous and liquid effluent release permits, the annual REMP report, and the annual effluent report, which included a summary of the radioactive waste management and transportation programs. The inspectors observed work activities associated with the processing, packaging, storage, and shipment of radioactive waste.
The inspectors observed maintenance activities related to the removal of shielding and scaffolding from the transfer tube vault on the 119' elevation of the Auxiliary Building to verify that appropriate personnel safety, fire protection, and radiation safety considerations were established. The inspectors also reviewed survey results related to removal of equipment and scaffolding from the Auxiliary Building and the Reactor Building. Inspectors performed checks of radiation survey instruments throughout the Auxiliary Building to determine if instruments were within calibration and daily performance checks had been completed.
The inspectors reviewed the procedure associated with the As Low As Reasonably Achievable (ALARA) Committee and reviewed the minutes from the last two ALARA Committee meetings to verify that Duke Energy's ALARA program was being effectively implemented. The inspectors verified ALARA meetings were attended by designated staff representatives and the meetings addressed the topics outlined in the procedure.
In addition, the inspectors reviewed High Risk radiological briefing records and discussed the activities with the radiation protection staff. The inspectors accompanied a Florida Department of Health inspector during their performance of environmental sampling, which included vegetation and water sampling.
The inspectors reviewed a sample of Job Performance Measures (JPMs) associated with the licensee's operator requalification program. The inspectors reviewed six JPMs which consisted of activities limited to non-operational activities, such as shutdown cooling, fuel handling, support systems, fire protection, and associated activities. The written exam was given in the second quarter of 2013 and was documented in NRC Inspection Report 05000302/2013003 (ML13240A155). The inspectors assessed the effectiveness of Duke Energy in implementing requalification requirements identified in 10 CFR Part 55, "Operators' Licenses." The inspectors evaluation was also performed to determine if Duke Energy effectively implemented operator requalification guidelines established in NUREG-1 021, "Operator Licensing Examination Standards for Power Reactors."
b. Observations and Findings
The inspectors noted that staffing at CR-3 had decreased by approximately 50 percent from the date when Duke Energy announced the site had permanently ceased operations. The inspectors also noted that reviews were continuously being performed Inspection Report No. 05000302/2013008 G:\WordDocs\Current\lnsp Letter\LDPR-72.2013008.doc
by Duke Energy to ensure that adequate staffing levels were being maintained to support plant activities. In-processing training programs were still in effect and job specific training programs were being modified to reflect the need for more contract workers in the future.
The inspectors attended pre-job briefings and determined that briefings were thorough and identified the significant potential hazards for the activities to be performed. The inspectors verified that the programs for the safe wet storage of spent fuel were being performed within the established frequencies and that the equipment was being properly maintained. The inspectors verified that the maintenance and surveillance program for systems and components had been conducted in accordance with the TS requirements and established procedures.
The inspectors determined that survey records were clear and complete and radiation protection staff and maintenance supervision effectively controlled work activities.
The annual radiological effluent and the annual REMP reports demonstrated that calculated doses were below regulatory dose criteria of 10 CFR 50, Appendix I. The inspectors also determined that waste treatment systems were maintained and operated in accordance with procedures and were being used to empty and process liquid from tanks and systems scheduled to be abandoned. The inspectors verified that liquid and gaseous effluent releases to the environment were controlled, monitored, and quantified as required by NRC regulations. The inspectors verified that radwaste shipping paperwork was properly completed and plant staff was knowledgeable of their duties and responsibilities. Duke Energy had performed required audits and Quality Assurance surveillances of their radioactive waste control program.
The inspectors determined that issues were entered into the CAP, prioritized, and evaluated commensurate with their safety significance. Corrective actions were implemented to address identified issues and were being tracked to closure.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.0
Exit Meeting Summary
On October 3, 2013, the inspectors presented the inspection results to Mike Delowery, Decommissioning Planning Manager, and other members of Duke Energy's staff.
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PARTIAL LIST OF PERSONS CONTACTED Licensee B. Akins, Radiation Protection and Chemistry Manager C. Aim, Criticality Engineer S. Balliet, Systems Engineer C. Berkdoff, Engineering R. Biddleman, Superintendent, Nuclear Oversight S. Bowden, Performance Support Supervisor C. Burtoff, Radiation Protection Specialist J. Connor, DTO Engineering M. Delowery, Decommissioning Planning P. Dixon, Decommissioning Support Manager F. Dola, DTO Plant Support J. Endsley, Lead Electrical & Design Engineer J. Ferguson, Shift Senior Reactor Operator J. Lane, Lead System Engineer, Spent Fuel Pool System Engineering P. Hanes, Systems Engineer D. Herrinon, Lead Licensing Engineer P. Hinnan, Systems Engineer A. Kennedy, Senior Nuclear Operations Instructor R. Kessner, Senior Reactor Operator W. Kisner, Jr., Senior Reactor Operator R. Macko, Senior Radiation Control Specialist G. McCallum, Operations S. McDaniel, Senior J_icensing Engineer L. Moffatt, Senior Reactor Operator R.W. Penner, Senior Chemistry Specialist J. Ramos, Radiation Protection Technician R. Sweeney, Senior Nuclear Operations Specialist K. Shelton, Radiation Protection Supervisor D. Sumner, Radiation Protection Technician M. Schwall, Radiation Protection Technician ALARA D. Westcott, DTO Licensing B. Wunderly, Plant Manager ITEMS OPEN, CLOSED, AND DISCUSSED None Inspection Report No. 05000302/2013008 G:\WordDocs\Current\lnsp Letter\LDPR-72.2013008.doc
LIST OF
DOCUMENTS REVIEWED
Action Requests
00627826,00628322, 00628642, 00628844, 00629021, 00629226,
00629551,00630219,00630248,00632352,00629650,00629827,00629790,00631307,
00631429,00621209,00624316,00624995,00627846,00629404,00623672,00628746
Calculations
CR3-13-03-200-001, URS Structural Design Basis for the CR3 Containment Building, Rev. 4
CR3-13-05-1 00-020, URS Containment Stabilization Recommendations, Revision 0
CR3-13-05-115-003, Analysis of Bay 61 Repair, Revision 1
CR3-13-05-115-009, URS Displacement Analysis of Containment Penetrations, Revision 1
CR3-13-05-260-001, URS CR3 Post Processor for Allowable Working Stress Design
Redacted, Rev. 2
CR3-13-05-261-002, URS Design Code Checks for Current Condition, Revision 1
CR3-13-05-261-003, URS Design Code Checks during Bay 61 Repair, Revision 1
S13-0005, Analysis of Containment Stabilization
Drawings
CR3 Containment Structure Detensioning Sequence Drawing
Drawing 30616-85168-001, Knockout 23-A 1 Elev: 167'-6" Plan, Revision 2
Drawing 30616-85168-002, Knockout 23-A2 Elev: 165'-6" Plan, Revision 2
Drawing 30616-85168-003, Knockout 2-A Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-004, Knockout 3-A Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-005, Knockout 14-A Elev: 143'-0" Plan, Revision 0
Drawing 30616-85168-006, Knockout 15-A Elev: 143'-0" Plan, Revision 0
Drawing 30616-85168-007, Knockout 9-1 Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-008, Knockout 20-1 Elev: 149'-0" Plan, Revision 0
Drawing 30616-85168-009, Knockout 1-A Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-010, Knockout 10-1 Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-011, Knockout 11-1 Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-012, Knockout 12-1 Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-013, Knockout 4-0S Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-014, Knockout 5-0S Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-015, Knockout 6-0S Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-016, Knockout 7-0S Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-017, Knockout 13-A Elev: 143'-0" Plan, Revision 0
Drawing 30616-85168-018, Knockout 16-1 Elev: 149'-0" Plan, Revision 0
Drawing 30616-85168-019, Knockout 17-1 Elev: 149'-0" Plan, Revision 0
Drawing 30616-85168-020, Knockout 18-1 Elev: 149'-0" Plan, Revision 0
Drawing 30616-85168-021, Knockout 19-1 Elev: 149'-0" Plan, Revision 0
Drawing 30616-85168-022, Knockout 22-A Elev: 167'-6" Plan, Revision 0
Drawing 30616-85168-023, Knockout 21-A Elev: 200'-4" Plan, Revision 0
Drawing 30616-85168-024, Knockout 24-A Elev: 162'-0" Plan, Revision 0
Drawing 30616-85168-025, Knockout 8-1 Elev: 119'-0" Plan, Revision 0
Drawing 30616-85168-026, Section A-A, Revision 0
Drawing 30616-85168-018, Knockout 16-1, Elevation 149'-0", Plan
EC Sketch SK 75220-C002, Embedded Instruments Location Map
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EC Sketch SK-91276-001, Buttress 2
EC Sketch SK 75220-C002, Embedded Instruments Location Map
Partial Drawing 421-231, EC 91276, Revision 0
Partial Drawing 421-237, EC 91276, Revision 0
Partial Drawing 421-238, EC 91276, Revision 0
PartiaiDrawing 521-012, EC 91276, Revision 0
Partial Drawing 521-102, EC 91276, Revision 0
Partial Drawing 522-003, EC 91276, Revision 0
S-425-004, IWE/IWL Inspection Vertical Tendon Layout, Revision 1
S-425-005, IWE/IWL Inspection Hoop Tendon "13" Layout, Revision 1
S-425-006, IWE/IWL Inspection Hoop Tendon "42" Layout, Revision 1
S-425-007, IWE/IWL Inspection Hoop Tendon "53" Layout, Revision 1
S-425-008, IWE/IWL Inspection Hoop Tendon "64" Layout, Revision 1
S-425-009, IWE/IWL Inspection Hoop Tendon "51" Layout, Revision 1
S-425-010, IWE/IWL Inspection Hoop Tendon "62" Layout, Revision 1
SK 74801-2, Acoustic Emissions Monitoring Instrumentation Location Map
Sketch SK-91276-002, Details
Sketch SK-91276-003, Details and Notes
Sketch WP-3740-003, Auxiliary Building Architectural Removal Roof Details, Revision 1
Sketch WP-3740-001, Auxiliary Building Roof Removal at Buttress 5, Revision 0
Procedures
ADM-01 05, ALARA Planning
AD-NO-ALL-0201, Responding to NRC Allegations and Comprehensive Employee Concerns
AD-NO-ALL-0202, Employee Concerns Program
AD-NO-ALL-1 000, Attachment 2, Nuclear Oversight Program Illustration
Al-1602, ALARA Committee
Al-9000, Conduct of Decommissioning
Al-9003, System Evaluation and Categorization
CH-513A, Spent Fuel Coolant Sampling
CP-161, Environmental Monitoring Program
HPP-240, Sampling for Part 61 Waste Stream Analysis
HPS-NGGCC-0001, Radioactive Material Receipt and Shipping Procedures
JPM 1A, Respond to a Fire in the Nuclear Sample Room, Revision 1, 9/4/13.
JPM 2A, Respond to a SW Leak, Revision 1, 9/4/13.
JPM 03, Determine External Reporting Requirements, Revision 0, 9/4/13.
JPM 04, Using Survey Maps to Determine Stay Times, Revision 0, 9/4/13.
JPM 05, Cross Connect EDG Fuel Oil Supplies, Revision 0, 9/4/13.
JPM 06, Start IAP-4 Locally, Revision 1, 9/4/13
PY-NO-ALL-0200, Safety Conscious Work Environment
SP-736L, Liquid Releases to the Discharge Canal via RM-L2
SP-736M, Liquid Releases to the Discharge Canal via RM-M2
SP1, Air Sampling
SP2, Collection of Fauna, Fish, and Oysters
SP4, Collection of Surface Water
SP5, Collection of Broad Leaf Vegetation
SP6, Collection of Food Crops
SP7, Shoreline Sediment, Soil, or Beach Sand
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SP1 0, Collection of Milk
SP12, Annual Land Use Census
SP13, Collection of Drinking Water and Ground Water
SP-334A, SFP-1A Quarterly Surveillance
SP-340B, DHP-1A, BSP1A and Valve Surveillance
SFP Chemistry and Cleanliness Analysis Graph
TAP-413, Conduct of Operator Continuing Training, Revision 20, 7/26/12.
TAP-426, Licensed Operator Continuing Training Biennial Written Examinations, Revision 8,
5/3/12.
TPP-200, Licensed Operator Continuing Training Program, Revision 14.
TRN-NGGC-0440, Regulated Exam Security, Revision 0.
TRN-NGGC-0441, Licensed Operator Requal Annual/Biennial Exam Development, Revision 1.
TRN-1 000, DTO-Performance Based Training
Surveillance and Functional Testing
EMG-NGGC-001 0, Attachment 2, 50.54(q)(3) Evaluation Sheet, Screening/Evaluation Numbers
EREG 609102 and EREG 610019
Health Physics Survey Record 13-09-00075, Block Orifice Room/MUV-112
Health Physics Survey Record 13-09-0021, Maintenance Support Building
Health Physics Survey Record 13-09-0029, Maintenance Support Building
Health Physics Survey Record 13-09-0102, Maintenance Support Building
Health Physics Survey Record 11-07-0086, Transfer Tube Vault
Health Physics Survey Record 13-08-0203, Block Orifice Room
Preventive Maintenance Task list (Excerpt from Passport Database for Selected Spent Fuel
Pool Components)
Quarterly Waste Container Inventory, 2013
Radiation Work Permit #54, Task 1, Decommissioning Activities
Radiation Work Permit #1 054, Task 3, Decommissioning Activities
Radioactive Waste Shipment Log 2013
SP-340B, DHP-1A, BSP-1A and Valve Surveillance (Quarterly Results- September 2013)
Spent Fuel Pool Procedures and Surveillance Tests:
SFP Coolant Analysis Results
SP-192, High Density Rack Poison Sampling (SF Pool A)
SP-300, Operating Daily Surveillance Log (Excerpts for SFP SSC checks)
Miscellaneous
Al-9003, Attachment 2, SSC Category Determination Document, Carbon Dioxide System
ALARA Committee Meeting Minutes, May 22, 2013
ALARA Committee Meeting Minutes, August 11, 2013
ALARA Work Plan and In-progress ALARA Evaluations for DTO Scaffold Removal from Reactor
Building
Decommissioning Transition Organization (DTO), August 8, 2013
ERO, Key Position Status, October 3, 2013
Memo, C-DTO-FR-13-01, Focused Review Plan for the DTO, June 28, 2013
PCHG-DESG, Engineering Change, 0000093160RO, Carbon Dioxide System Abandonment
Plant Operating Manual CH-513A, Spent Fuel Coolant Sampling
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LIST OF ACRONYMS USED
A LARA As Low As Reasonably Achievable
CAP Corrective Action Program
CFR Code of Federal Regulations
CR-3 Crystal River Unit 3
Duke Energy Duke Energy Florida, Inc
EC Engineering Change
IMC Inspection Manual Chapter
IP Inspection Procedure
NRC U.S. Nuclear Regulatory Commission
REMP Radiological Environmental Monitoring Program
TS Technical Specifications
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